The URL can be used to link to this page

Home My WebLink About04-4243SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Plaintiffs ELIZABETH J. BEAM Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No. L~ ~-/-/~/./3 ~ CIVIL ACTION - LAW IN ASSUMPSIT NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing n writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY B ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, Pennsylvania 17013 Phone: 717. 249.3'166 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Date: SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Carol J. Lindsayl ID# 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Plaintiffs ELIZABETH J. BEAM Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No. CIVIL ACTION - LAW IN ASSUMPSIT COMPLAINT AND NOW COMES Saidis, Shuff, Flower & Lindsay, P.C. and states as follows: Plaintiff is a professional corporation with a primary place of business of 26 West High Street, Carlisle, Cumberland County, Pennsylvania 17013, Defendant is an adult individual who resides at 133 Rygate Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. On June 24, 2002 Plaintiff and Defendant entered into an agreement according to the terms of which Plaintiff was to provide legal services for Defendant upon terms set out in an engagement letter, a copy of which is attached hereto as Exhibit "A". Since June 24, 2002 Defendant has incurred legal fees pursuant to the parties agreement the unpaid balance of which is presently $23,488.19. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Date: WHEREFORE, Plaintiff prays this Honorable Court to enter a Judgment for Plaintiff and against Defendant in the amount of $23,488.19. Respectfully submitted, Saidis, S~huff, Elower & ID# 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 VERIFICATION I verify that the statements made in this COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the parities of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: Carol ~l,,i'n. dsay, Esquire Saidis Shuff Flower & Lindsay, P.C. 26 West High Street Carlisle, PA 17013 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Slreet Carlisle, PA _. ~$ D. FLOWER ) 01-5'4 f. SLE<E ROBERT C. SARDIS GEOFFREY S. BI-R/FF JA~M~:S D. FLOWER, JR. CAROL J. LINDSAY JOHNNA J. KOPECKY KARL M. LZDEBOH2vI JOSEPH L. HITCHI'NG$ THOMAS E. FLOVTER FORREST N. TROUTMAN, LAW OFFICES SAIDI$, SHUFF, FLOWER & LINDSAY A?ROFESSIONAL CORPORATION 26 WEST H/GH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-6222 - FACSEvIU-E: (7/7) 243-648 EivLA/L: a~omey~, ss fl-la~y.com JUN 2 6 2002 WEST SHORE OFFICE: 2109 MARKET STREET CA/v~ H/LL, PA 17011 TELEPHONE: (717)737-3405 FACSIMILE: (717)737-3407 REPLY TO CARLISLE June 7,2002 Elizabeth Pecora 421 C. Street Carlisle, PA 17013 Dear Ms. Pecora: You have asked our law firm to act as your attorneys. This letter sets forth the agreement (ff",,nceming our representation of you. This agreement shall become effective upon our receipt of a .--d'U;ntersigned ~opy of this letter and the retainer fee, at which time, work on your case will begin. 1. You hereby agree to pay our firm a retainer fee of $2,500.00 which is paid to us for the purpose of assuring our availability in your matter. Your retainer fee will include the initial consultation and the balance will be credited to your account for services to be performed in the future. The retainer is non- refundable. We will apply your retainer against time expended on your behalf, and at such time as that amount is exhausted, you will be bi!led regularly for additionai time expended. 2. The basis for our fee is the amount of time spent on your matter. It is impossible to determine in advance the amount of time that will be needed to complete your case. Our billing is based on an hourly rate of $175,00 per hour. This hourly rate will prevail until December 31,2002, after which, due to rising costs and ovemead expenses, the hourly rate will be subject to increase in accordance with the then existing hourly rate schedule. We will bill you monthly on a time-expended basis. Although we do send itemized bills as a matter of course, we do maintain in our office records of time used for conferences, telephone calls, correspondence, electronic communications, drafting documents, research, court time, and if necessary, tra~)el time. These records will be available to you upon request. Fractions of hours are computed in periods of not less than two tenths (.2) of an hour and the interruption of other work is taken into consideration. If some of the work on your case can be done by a -alegal or by a law clerk whose hourly time rates are substantially lower than mine, to the extent that :-~ir time is utilized, the overall fee will be lower. You will not be billed for clerical or secretarial time. If it Elizabeth Pecora uno 7, 2002 Page 2 of 2 is necessary to prepare interrogatories, pleadings, a property settlement agreement, or similar legal documents on your behalf, there will be a base charge for such pleadings or agreements, plus an houdy rate for amendments and revisions. For the preparation of certain documents you will be billed on a fiat rate basis rather than a time expended basis. 3. We expect you to keep current with our billings. We reserve the right to terminate our attomey- c!ient relationship foe non-paymen~ of fees or' co,ts. Ur~paid fees incur interest at 1.5% per month. 4. "Costs" are our out-of-pocket expenses, such as filing fees, transcripts, photocopies, long distance phone calls and, if necessary, appraisals and accounting fees. Costs will be billed on a monthly basis. 5. On some occasions, a court will order one spouse to pay part or all of the other spouse's fees. Often, the court makes no order for fees and costs. However, as our client, you are primarily responsible for the payment of our total fee. Of course, amounts received pursuant to court order will be credited to your account. 6. Please date and countersign this agreement and return the original to us, together with the retainer, in the enclosed retum envelope, so that we will have a mutual memorandum of our understanding. You should retain the copy for your file. CJL/tjb Enclosures Very trdly yours, SAID,S, S~F~/~ER & LINDSAY Carol J. Li/~sA~y hereby accept the terms set out above and acknowledge same by signing this copy. SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Plaintiffs ELIZABETH J. BEAM Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No. ~ : CIVIL ACTION- LAW PRAEClPE FOR THE ENTRY OF A JUDGMENT BY CONSENT To the Prothonotary: Enter Judgment for Saidis, Shuff, Flower & Lindsay P.C. against Elizabeth J. Beam by consent of the parties in the amount of $23,488.19. Saidis,~O-ff, F/I~ Lindsay, P.C. ID# 446~3 26 Wes HJt~treet Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA !man, P.C. ire man, P.C. Ste. #3 ~.~His~o, PA 17013 SAIDIS HUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Plaintiffs ELIZABETH J. BEAM Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA - Docket No. /__.)/'~- ~,LI'~ C., v~ I CIVIL ACTION - LAW ACCEPTANCE OF SERVICE I, James D. Hughes, Esquire, attorney for the Defendant herein, accept service of the Complaint in the captioned case and certify that I am authorized to do so. Da s D. Hughes, Esquire CalAmann Hughes & Fishman, P.C. le,'~ander Spring Rd. Ste #3 islE,, 17013 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Plaintiffs V. ELIZABETH J. BEAM Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No. 2004-4243 CIVIL ACTION - LAW To the Prothonotary: PRAECIPE Please mark the Judgment in the captioned case satisfied. Date: Saidis, Shuff, Flower & Lindsay, P.C. (717) 243-6222